An overly aggressive Phase I emission reduction target, now increased from a 10 percent to a 15 percent reduction of greenhouse gas emissions below 2005 levels by 2020, before the anticipated commercial availability of carbon capture and storage technologies;

An unequivocal commitment to achieving a 70 perscent national emision reduction below 2005 levels by 2050, regardless of the degree of subsequent participation of major developing nations like China and India in a global climate protection framework;

The failure to identify “domestic economic development” as a finding of Congress, a purpose of the legislation, and the failure to require that funding from this legislation be dedicated to domestic investments for new technology and the creation of jobs – from production to construction and exports.

The absense of an effective safety valve price for carbon dioxide allowances, which will have an adverse impact upon investment decisions and consumer and inducstry pricing.

The need for a restricted and regulated market system that does not fall prey to predatory trading practices, hoarding of allowances, and the creation of carbon billionaires, which an open market and unlimited banking of allowances can lead to.

The extent of the use of international allowances combined with offsets, and he possibility of double dipping with offsets by providing allowances for activities that would have been done anyway.

Inappropriate allocations of emissions allowances, such as the 10 percent allocation to “wires companies” to encourage energy efficiency – a goal that may be better accomplished through direct legislation on energy efficiency standards, now incorporated in other provisions of the bill.